At the request of perennial Endangered Species Act critic Congressman Richard Pombo (R-CA), the United States Government Accountability Office has spent a year reviewing U.S. Fish and Wildlife Service expenditures on threatened and endangered species. The report, entitled “Fish and Wildlife Service Generally Focuses Recovery Funding on High-Priority Species, but Needs to Periodically Assess Its Funding Decisions” was publicly released on April 26, 2005.

Unhappy with the positive review, Rep. Pombo immediately sent out a misleading press release entitled “GAO Endangered Species Report: Little Reason to Expect Poor Recovery Record To Improve.” Pombo lied. The GAO report did not conclude that the Endangered Species Act has a poor recovery record. It did not even analyze this issue. Nor did it conclude that endangered species are unlikely to recover in the future. In fact, it did not recommend any changes to agency spending patterns. It instead noted proponents of endangered species recovery and U.S. Fish and Wildlife Service biologists agree that Congress’s failure to provide adequate funding is a major stumbling block to recovery. Congressman Pombo has consistently led the way in limiting Endangered Species Act funding.

“The Endangered Species Act is America’s safety net for imperiled plants and animals,” said Kieran Suckling, policy director of the Center for Biological Diversity. “It is good to see that the U.S. Fish and Wildlife Service is funneling its scarce resources to the most endangered species. If Congress would get off the dime and provide the agency with the money it needs, the grizzly bear, southern sea otter, Florida panther, and western lily would recover even faster. Congressmen like Richard Pombo give new meaning to the phrase ‘penny wise, pound foolish.’ They are impeding the protection of our nation’s natural heritage and burdening future generations.”

The U.S. Fish and Wildlife Service assigns a recovery priority number between one and 18 to each of the 1,252 endangered species under its jurisdiction. The GAO placed these species in six groups of descending priority: 1-3, 4-6, 7-9, 10-12, 13-15, and 16-8. It determined that the agency spent 44% of its recovery funds on the highest-priority group, 28% on the second-highest group, and 23% on the third-highest group. These groups respectively contain 33%, 36%, and 23% of listed species. The three lowest-priority groups combined received just 6% of agency funding and comprised just 8% of listed species. In the GAO’s own words:

“The Service spent its recovery funds in a manner generally consistent with species
priority in fiscal years 2000 through 2003, spending almost half (44 percent) of the $127
million on the highest priority species. Species in the next two highest priority groups
received almost all of the remaining recovery funds (51 percent). Species in the three
lowest priority groups received very little funding (6 percent).” (p. i)

The GAO also found that average funding per species generally matched biological priorities. It noted that two significant deviations were purposefully carried out by the Fish and Wildlife Service. The agency spent considerable funds on the American bald eagle and Canada lynx (both low-priority species) because it is trying to push the former over the last hurdles to full recovery and resolve contentious habitat loss controversies involving the latter. In the GAO’s own words:

“(A)nalysis of average spending on a per species basis also reveals that more
expenditures are made on higher priority species. Additionally, the analysis shows
the emphasis the Service placed on species with a high degree of recoverability.
The relatively large amount of funding spent on species with low priority rankings
(13 through 15) is greatly influenced by spending on the bald eagle (with a priority
ranking of 14c) and the Canada lynx (with a ranking of 15)...When spending on these
two species is removed, the average amount spent on species in this priority group
is significantly lower.” (p. 16)

The GAO noted that while spending does reflect the priority system, the U.S. Fish and Wildlife Service does not directly use the priority system to allocate funds. It uses a more complex decision-making process that also considers availability of matching funds from partner groups, impact of spending on entire ecosystems, and achieving swift recovery for species like the bald eagle and Columbia white-tailed deer, which are almost recovered. The GAO did not suggest that the Fish and Wildlife Service alter its decision-making system, but did recommend that it better document the reasons for its decisions and better monitor the results. The Center for Biological concurs with these recommendations.

Always an opponent of the Endangered Species Act, Representative Pombo is unhappy that the GAO report generally affirms the U.S. Fish and Wildlife Service’s recovery spending decisions. Thus he sent out a press release on April 26, 2005 substituting his own conclusions for theirs. Pombo’s ‘summary’ is less a presentation of the GAO said than his own political wish list of what he hoped it would say. Pombo requested the GAO study; the least he can do is fairly represent it. For a politician who routinely postures about “sound science” he has bent over backward to misrepresent the GAO’s analyses.

Analysis: The GAO report did not conclude that the Endangered Species Act has a poor recovery record. It did not even analyze this issue. Nor did it conclude that endangered species are unlikely to recover in the future. These are Pombo’s controversial opinions and have nothing whatsoever to do with the GAO study.

Pombo: “GAO found that FWS generally spends its funds on higher priority species. However these expenditures may not mean much upon examination of the priority ranking system. GAO found that FWS ranked 92 percent of animals and plants in the upper half of the priority system, a strong sign that the assigned priorities are not efficient.”

Analysis: The GAO did not conclude that the USFWS priority system is “not efficient” or criticize it any way. In fact it expressly stated “We did not make a judgment about the adequacy or accuracy of the Service’s recovery priority system” (page 33). While pretending to summarize the GAO report, Rep. Pombo is actually presenting his own pre-determined conclusions without providing any scientific basis for them.

The GAO divided all species into six priority groups (1-3, 4-6, 7-9…16-18) and determined the total USFWS money spent on each group and the average amount of spent on each species in each group. It found that:

“The Fish and Wildlife Service has spent its recovery funds in a manner generally
consistent with its recovery priority guidelines. For fiscal years 2000 through 2003,
the Service spent nearly half (44 percent) of the recovery funds attributable to
individual species on species with both a high degree of threat and a high potential
for recovery (see fig. 1). These species constitute one-third of all endangered and
threatened species, and they received, on average, more funding than species that
were lower priority. Of the remaining recovery funds, almost all (51 percent) was
spent on species in the next two highest priority groups—species with a high threat
assessment but a low potential for recovery, and species with a moderate threat
assessment but a high potential for recovery. Very little (6 percent) was spent on species
in the remaining three lowest priority groups and most of this is attributable to spending on
two species: the Bald Eagle (which is nearing delisting) and the Canada Lynx (which
was embroiled in controversy). (Page 3).

Pombo: “The report released today noted that not a single plant or animal with the highest recovery priority was among the 20 species receiving the most recovery dollars.”

Analysis: While it is true that no species with the highest priority ranking (i.e. 1) were in the top twenty for USFWS expenditures (see table 4, page 29), it is not true that the GAO “noted” or in any way mentioned this fact. Why didn’t the GAO find this to be a noteworthy fact? First the distinction between priority rankings of 1, 2 and 3 are not scientifically significant. Indeed, the GAO expressly rejected the idea of analyzing the data as such small scales: “We grouped together species with similar rankings [i.e. 1-3, 4-6, 7-9…16-18] to deemphasize minor differences in species’ rankings” (page 34, emphasis added). In his obsessive quest to find fault with the U.S. Fish and Wildlife Service and the Endangered Species Act, however, Rep. Pombo leapt off the analytical cliff that the GAO wisely avoided. He landed in statistical gibberish.

Secondly, the amount of money needed to recover individual species varies dramatically depending on how much land each ranges over, what threats it faces, and what recovery strategies are required. To emphasize this point, the GAO noted the total funds needed to recovery individual species range from $18,000 to $108 million (page 35). Thus there is no logical reason to expect USFWS to annually spend more funds on priority 1 species with small ranges like the Comal Springs dryopid beetle, Kauai cave amphipod, Kauai cave spider, Alabama cave fish, swamp pink (a plant), and Newcomb’s snail than on priority 2 or 3 species with large ranges like the northern spotted owl, Mexican gray wolf, grizzly bear, and black-footed ferret. The latter species naturally require more funding.

Contrary to Pombo’s statistical jerrymandering, the GAO grouped all priority 1, 2, and 3 species together (and 4-6, 7-9, etc.) to obtain statistically meaningful sample sizes. It found, quite contrary to Rep. Pombo’s assertions, that the USFWS spending patterns generally reflected these priorities. In specific cases where the agency diverted from the priority system, it often did so for clear reasons. Thus the American bald eagle (a low priority species) received large funding because the agency is trying to push it over the last hurdles to total recovery. The Canada lynx (another low-priority number) received high funding in order to resolve widespread habitat loss controversies.

Pombo: “Despite the fact that a “species’ ” genetic distinctiveness ranks higher than a "subspecies'," GAO found subspecies got more than twice the funding species received.”

Analysis: Rep. Pombo has misrepresented the priority system. All monotypic geni are not ranked higher than all species, and all species are not ranked higher than all subspecies. Indeed the GAO noted that taxonomic status is just one of three variables that determine the priority number (page 10). It is the least important of the three. For example, a subspecies that is highly recoverable and faces a high degree of threat will always have a higher priority number than a species with a moderate degree of threat or a monotypic genus with a low likelihood of recoverability. Thus there is no basis for Rep. Pombo’s complaint. And indeed, the GAO made no complaint about USFWS spending patterns in relationship to taxonomy and made no suggestion to change the pattern.

Pombo: “GAO also found funding decisions were based to a "significant extent" on factors other than recovery priority and that each regional office allocated funding differently, "but in no case was priority the driving factor."

Analysis: The GAO did find that the USFWS employed other factors in addition to recovery priority numbers to allocate funding, and that in no case were recovery priority numbers the only factor. But contrary to Pombo’s implication, the GAO did not conclude that this is improper, illegal, or unwise. Pombo is trying to invent a scandal where the GAO found none.

The GAO likely did not find a great problem in including factors other than priority numbers in funding decisions because it found that these other factors did not cause the agency to greatly deviate from the priority system. The report’s primary conclusion is that the agency’s spending patterns do generally accord with recovery priority numbers.

The only GAO’s only suggestion regarding the relationship between funding decisions and recovery priority numbers is that the agency better document and monitor its decision so that it can explain them to the public:

“To help ensure that the Service allocates recovery resources consistent with the
priority guidelines over the long term and in a transparent fashion, we recommend
that the Secretary of the Interior require the Service to take the following two actions:
(1) periodically assess the extent to which it is following its recovery priority guidelines
and identify how factors other than those in the guidelines are affecting its funding
allocation decisions, and (2) report this information publicly, for example, in its biennial
recovery report to Congress.” (Page 31)

Pombo: “The recovery program's poor record of bringing species to a point at which they may be taken off the list has been plagued by the program's skewed assessment of recovery priorities, the disproportionate expenditures on subspecies and the lack of a uniform system to ensure recovery dollars go to the highest priority species.”

Analysis: The GAO did not conclude that the USFWS has a poor rate of recovering endangered species. It did not conclude that the USFWS has a skewed assessement of recovery priorities. It did not assert that subspecies should receive less money than other taxa. And it did not conclude that lack of uniformity in recovery spending has hindered recovery trends. Pombo’s tirade has virtually no relationship to the GAO report.

Pombo: "This is not encouraging," said Pombo. "There is little reason to believe focused conservation efforts will improve the current meager rate of species recovery under the ESA".

Analysis: The GAO did not make this conclusion or even discuss the topic. Pombo has provided no basis for strange assertion that “focused conservation efforts” are unlikely to help recover species. He certainly doesn’t find any support in the GAO report. Contrary to Rep. Pombo’s rhetoric, scientific studies have repeatedly shown that great funding levels make species more likely to recover. And one only need glance at the highly focused recovery efforts for the bald eagle, peregrine falcon, Aleutian Canada goose, American alligator, whooping crane, grey whale, grey wolf, and Robbins cinquefoil to see that they have been very successful. When the agency focuses significant funding and conservation actions on endangered species it can clearly improve their status.